“Under Direction”: The Line RTOs Cross Without Realising

“Under Direction”: The Line RTOs Cross Without Realising

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Credential Policy · 1B–1D

“Under Direction”: The Line RTOs Cross Without Realising

“Under direction” is useful, common, and constantly misapplied. The Credential Policy lets people who don’t yet hold the full credentials deliver training and contribute to assessment under direction. Used correctly it grows your workforce. Used loosely, it quietly puts invalid assessment judgements into your system.

The line that gets crossed

Here’s the scenario I see again and again: a trainer working under direction is clearly capable, it’s convenient, and they quietly start signing off assessment judgements. Capability feels like enough. But capability is not the test — permission is. If the policy doesn’t permit that person to make the judgement, the judgement is exposed no matter how good it is.

From the audit table: “under direction” problems are rarely about bad people. They’re about good people doing slightly more than they’re permitted to, with no documentation to define where the line was. The fix is almost always paperwork and clarity, not capability.

How the Credential Policy structures it

The policy distinguishes delivering and assessing without direction (full credentials, section 1A) from working under direction (sections 1B–1D), for people who don’t yet hold those credentials. The detail was deliberately clarified because wording around whether under-direction staff could make assessment judgements was causing confusion. The safe reading: under-direction arrangements have boundaries, and assessment judgement is the boundary most commonly crossed.

Where it goes wrong

  • No documented supervision. “They work under our senior trainer” is not evidence. The arrangement, supervisor and scope must be on paper.
  • Judgements by people not permitted to make them. The big one — it can render judgements invalid.
  • An uncredentialled supervisor. The person giving direction has to hold the right credentials themselves.
  • Permanent workaround. Under direction is a pathway, not an indefinite substitute for credentialling your people.

How to get it right

  1. Document every arrangement. Name the person, the supervisor, the scope and the limits — in writing, kept current.
  2. Confirm the supervisor’s credentials. They must hold the credentials the policy requires.
  3. Draw the judgement line clearly. Everyone knows what under-direction staff can and cannot sign off — and it’s enforced.
  4. Treat it as a pathway. Pair it with a plan to reach full credentials, so it’s genuinely transitional.
Is your “under direction” documented?

The free checklist includes the Credential Policy checks auditors test.

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Frequently asked questions

Delivering training and contributing to assessment while working under the direction of a suitably credentialled trainer and assessor, in the circumstances set out in sections 1B–1D of the Credential Policy. It applies to people who don’t yet hold the full credentials to operate without direction.
Under-direction arrangements have boundaries, and assessment judgement is where RTOs most often go wrong. Confirm precisely what the person is permitted to do and ensure judgements are made only by those allowed to make them.

Yes. The person providing direction must hold the credentials required to deliver and assess without direction. An uncredentialled supervisor undermines the whole arrangement.

Keep reading

The currency gap hiding in your trainer files

The pre-validation trap that fails more RTOs than anything

Run the audit-readiness checklist

About the author

Ben Thakkar

Ben Thakkar

15+ yrs experience

Compliance, Training & Business Specialist · VET Advisory Group

Ben Thakkar is a Compliance, Training, and Business specialist in the education industry. He has held senior management roles, including General Manager, with leading Registered Training Organisations (RTOs) and Universities. With over 15 years of experience, Ben brings extensive expertise across audits, funding contracts, VET Student Loans, CRICOS, and the Standards for RTOs 2025.

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